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Bullseye Glass Co 3-8-16
Bullseye Glass Co 3-8-16
(503) 229-5696
FAX (503) 229-6124
TTY711
March 8, 2016
Sent via email and U.S. Mail
Jeff Hunter
Perkms Coie, LLP
1120 NW Couch Street, 10th Floor
Portland, OR 97209-4128
Thank you for working with DEQ staff regarding Bullseye Glass Co.'s (Bullseye's) operations,
use of metals in its glass making processes, and air emissions that result from those operations
and processes. The Department of Environmental Quality (DEQ) appreciates the interim
voluntary steps that Bullseye has taken to cease use ofarsenic, cadmium, and all chi'omium
while considering an agreement to specify conditions under which DEQ would agree that the
company's continued operations are appropriately protective of human health and the
environment during an interim period while Bullseye works to install effective emissions control
equipment designed to provide a long-term means to prevent significant air toxics emissions
submit a source test plan detailing the approach to DEQ for approval;
Test while making a glass that contains trivalent chromium, and under operational
conditions that are agreed to by DEQ as representing conditions most likely to result m
the conversion oftrivalent chromium to hexavalent chromium;
Keep records of the amount of chromium III used in the batches that are produced during
the source test runs, as well as other operational parameters identified in the source test
plan; and
Prior to the source test, clean the furnace stack in a manner that has been approved by
DEQ and complies with applicable OSHA standards or replace the furnace stack to be
tested.
Third, keeping daily records of all batches produced and providing to DEQ, each week, the daily
amount ofDEQ monitored metals used.
IfBullseye agrees to these terms, the above provisions will be incorporated into the agreement
that we have been developing to address concerns with air emissions from the Bullseye facility.
DEQ will continue to operate its ambient air quality monitors now located in the vicinity of
Bullseye^s facility to assure that air quality is safe for public health and the environment. If
Bullseye elects to operate using trivalent chromium without an agreement with DEQ as
described above, DEQ is prepared to take appropriate action in the event that monitoring
indicates emissions of hexavalent chromium at levels that present a significant risk to public
health or the environment. In addition, DEQ expects that Bullseye will continue to honor its
commitment to not use cadmium, arsenic or hexavalent chromium until appropriate emissions
controls are installed. Finally, Bullseye also should be aware that DEQ will recommend to the
Environmental Quality Commission that it adopt temporary rules m the near future that will
confirm requirements for air emissions controls for certain glass manufacturers currently
operating uncontrolled furnaces. It is expected that these requirements will apply to Bullseye
and similarly situated facilities where uncontrolled emissions may result in ambient air quality
that presents an unacceptable risk to public health or the environment.
Bullseye Glass has worked cooperatively with DEQ and other public agencies to address
concerns with its air emissions. We are similarly committed to identifying how Bullseye can
continue to operate in a manner that is protective while permanent emissions controls are put in
place. Please let us know how Bullseye intends to proceed.
Sincerely,
t^
fl-i-'Hammond
Deputy Director